I appreciate the initiative on the new safety and security rating system for chemical plants by the Indian Government and am sharing my comments sent to the Ministry on the new safety rating system:
1. The initial screening criteria will eliminate
many of the existing chemical units in the small and medium scale sector which also
handle highly hazardous chemicals. In
such a case, what will be the action? I suggest that Initially, for SME sector,
certification to OHSAS 18001 could be made mandatory and the proposed safety
and security rating system be applied to MAH units. Later the modalities to
extend it to SME sector could be worked out.
2.
In the initial screening criteria, one of the
KPI’s is mentioned as “approved and documented PSM system available and
implemented”. There is no reference to which PSM model to follow. I suggest
that the basic OSHA CFR 1910.119 PSM rule of USA be followed. The threshold
limit of chemicals for which PSM system applies could be the same list used in
MSIHC rules.
3. Any
rating system is a snapshot of the organisations safety performance. However,
in process safety management, top management commitment and technical
competency of the people who run the system are important for achieving
incident free performance. The proposal for the new safety rating system
suggests that organisations with good safety performance will be incentivized. The opposite of this must also be
implemented – if an organization that has been rated either 3,4 or 5 star in
the new rating system experiences a reportable accident ( as defined in factory
rules) after the award of the rating and within the periodicity of assessment,
then the rating should automatically be downgraded to “Poor”. This will ensure continued top management
focus. The list of organizations who have been thus downgraded may be
publicized on the Ministry of Chemicals and Fertilizers website or on a new
website specifically dedicated to the “Chemical Plant Safety and Security
Rating system”
4.
In the 19 KPI’s of final assessment, KPI’s 12,13
and 14 (Contractor management, emergency preparedness and response and training
and competency) are already covered in the PSM system mentioned in KPI 2. They
can be assessed as part of the PSM system.
5.
As the concept of “Occupier” and “Factory Manager”
is already legally required for companies, I suggest that both of them be
mandatorily assessed in final assessment on how they track PSM performance as
well as competency levels to maintain the PSM system.
6.
In the evaluation questionnaire for PSM, in
point 2.3, it is asked if QRA/LOPA is done for all operations and
recommendations implemented? Instead, the question could be Whether Hazard
Identification and risk analysis based on guidelines of IS 15526:2006 has been
carried out and recommendations implemented?
7.
Finally, the new rating system will be recognized
as unbiased and transparent by the public only if the if the assessment evidences
for those organisations that have been awarded “Good, Very Good and Excellent”
are posted on the website of the Ministry of Chemicals and Fertilizers or
on a new website specifically dedicated to the “Chemical Plant Safety and
Security Rating system”
END
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